What Is a Bill of Lading? Fields, Types, and Liability

Updated 2026-09-01

A bill of lading — “BOL” on the phone — is the document the carrier issues for freight it receives: it names the parties and the stops, describes what was tendered, and, once signed at delivery, becomes the proof of delivery a carrier invoices against.

Three different bodies of law point at that one piece of paper, and they answer three different questions. 49 CFR 373.101 says what has to be on it. 49 U.S.C. chapter 801 — the Federal Bill of Lading Act, still called the Pomerene Act — decides whether the document itself controls who gets the freight. 49 U.S.C. 14706 makes it the instrument a cargo claim runs under. The first is the easy one. The other two are where the money is, and they are the reason this page quotes the statutes instead of paraphrasing them.

If you need the document rather than the explanation, the bill of lading generator fills and prints a straight BOL with each field’s citation attached — free, no account, nothing uploaded. Everything below is why those fields are on it.

What the regulation actually requires

The requirement is short. 49 CFR 373.101 — headed “For-hire, non-exempt motor carrier bills of lading” — states that “Every motor carrier subject to § 373.100 shall issue a receipt or bill of lading for property tendered for transportation in interstate or foreign commerce containing the following information,” and then lists five items:

Two things worth pinning down.

It is a “receipt or bill of lading.” The regulation does not require a document titled “Bill of Lading,” and it never uses the word “contract.” Whether a given BOL also functions as a contract of carriage is a separate question the regulation does not answer — note that 49 CFR 370.3, the claims rule, phrases it as “the bill of lading or other contract of carriage.” Two federal regulations, two framings. Anyone who tells you flatly that the BOL is or is not the contract is compressing something the documents leave open.

It applies to the carrier, not to everyone. 49 CFR 373.100 scopes the subpart: “This subpart applies to motor carriers subject to 49 U.S.C. subtitle IV, part B (secs. 13101-14916).” The duty to issue is the carrier’s. As a broker you do not owe this obligation — but the document it produces is the one your rate confirmation makes a condition of payment, so its defects land on your desk anyway.

The field-by-field table

Five fields are required by 49 CFR 373.101. One more is a statutory duty rather than a regulatory one — the “nonnegotiable” marking under 49 U.S.C. 80103(b)(2). Everything else is on the document because leaving it off costs money. This is the same idiom as the rate con field table, with a column making the difference explicit.

Straight vs order: one line changes the document

The statute does not use the yard vocabulary. 49 U.S.C. 80103 speaks of negotiable and nonnegotiable bills; the revision notes to chapter 801 record that “negotiable bill of lading” was substituted for “order bill” and “nonnegotiable bill of lading” for “straight bill.” Same documents, older names.

Scope matters here: 49 U.S.C. 80102 applies the chapter to a bill of lading “issued by a common carrier” on the interstate and foreign movements it lists. It is not a rule about every piece of paper in the cab.

“Shipper’s weight, load, and count” does less than people think

The statute is unusually direct about this notation, and what it says is narrower than the stamp suggests.

Under 49 U.S.C. 80113(a), “a common carrier issuing a bill of lading is liable for damages caused by nonreceipt by the carrier of any part of the goods by the date shown in the bill or by failure of the goods to correspond with the description contained in the bill.”

Subsection (b) takes that liability away — but only on three conditions, and the statute joins them with “and,” not “or”:

1. “when the goods are loaded by the shipper”;
2. when the bill “describes the goods in terms of marks or labels, or in a statement about kind, quantity, or condition” or “is qualified by ‘contents or condition of contents of packages unknown’, ‘said to contain’, ‘shipper’s weight, load, and count’, or words of the same meaning”; and
3. “to the extent the carrier does not know whether any part of the goods were received or conform to the description.”

So the stamp is one of three conditions, not a switch. The operator shorthand — SLC, “shipper load and count,” “shipper load, stow and count” — falls under the statute’s “words of the same meaning,” so the wording on your BOL is not the issue. Who loaded, and what the carrier knew, is the issue.

And when the carrier loaded, the words do nothing. 49 U.S.C. 80113(d)(2) is worth reading twice:

“When goods are loaded by a common carrier, the carrier must count the packages of goods, if package freight, and determine the kind and quantity, if bulk freight. In that situation, inserting in the bill of lading or in a notice, receipt, contract, rule, or tariff, the words ‘shipper’s weight, load, and count’ or words indicating that the shipper described and loaded the goods, has no effect except for freight concealed by packages.”

A driver who watched the load go on, or handled it, and then stamped SLC has stamped something the statute says has no effect — outside the concealed-packages carve-out. There is a parallel rule in 80113(d)(1) for bulk freight: where the shipper makes adequate weighing facilities available and asks in writing, the carrier “must determine the kind and quantity of the freight within a reasonable time,” and inserting “shipper’s weight” then “has no effect.”

Separately, 80113(c) addresses damage from improper loading: the carrier is not liable for it if the shipper loaded and the bill carries “shipper’s weight, load, and count” or words of the same meaning. That is a narrower question than shortage, and it is the one the notation is actually good for.

The BOL in a cargo claim

49 U.S.C. 14706(a)(1) starts from the document: a carrier “shall issue a receipt or bill of lading for property it receives for transportation under this part.” Two later sentences in the same paragraph do the work that gets conflated. The first names who is liable: that carrier and “any other carrier that delivers the property” are “liable to the person entitled to recover under the receipt or bill of lading.” The second names what that liability covers — “the actual loss or injury to the property caused by” the receiving carrier, the delivering carrier, or “another carrier over whose line or route the property is transported”.

A connecting carrier is a category of cause, then, not a party the clause makes liable. Which is the useful half: it is why the receiving carrier cannot deflect a claim by pointing at whoever had the freight in the middle.

The same paragraph also settles which carrier counts as the delivering one, which matters the moment a load moves interline: it is “the carrier performing the line-haul transportation nearest the destination” and “does not include a carrier providing only a switching service at the destination.”

Two practical consequences. The phrase is “the person entitled to recover under the receipt or bill of lading” — so who is named on the BOL decides who can bring the claim, before anyone argues about damages. And the exceptions the carrier writes at delivery are the first evidence of condition anyone will look at, which is why a clean signature on a damaged load is expensive.

The deadlines, the acknowledgement duty, and how far the carrier’s liability can be limited are the Carmack Amendment’s subject, not this page’s.

How long you keep it

49 CFR 373.101 closes with “The carrier shall keep a record of this information as prescribed in 49 CFR part 379.” That part reaches further than carriers: 49 CFR 379.1(a) applies the preservation rules to “(1) Motor carriers and brokers; and (2) Household goods freight forwarders.” Brokers are named in the first item, so this schedule is yours as well as your carrier’s.

The retention periods sit in Appendix A. Under “I. Shipping and Agency Documents”:

One year is a floor, and it is shorter than two neighbouring obligations you already have. Your own broker transaction record runs three years under 49 CFR 371.3(b) — that rule and what it covers are on the rate confirmation page. And the minimum period a carrier may allow for suing on a cargo claim is two years under 49 U.S.C. 14706(e)(1), which starts from a written disallowance that may itself arrive months after delivery. 49 CFR 379.3 says the part “shall not be construed as excusing compliance with the lawful requirements of any other governmental body prescribing longer retention periods.” Purging BOLs at twelve months is compliant with part 379 and still leaves you holding a claim with no document.

Where bills of lading go wrong

Nobody wrote the arrival and departure times. The signed BOL is the detention evidence chain. Without times on it, the accessorial terms you negotiated on the rate con are unenforceable in practice.

The count on the BOL and the count on the rate con disagree. Now you have two documents describing one load, and the carrier will invoice from the one that favours it.

A clean signature on a damaged load. Exceptions are noted at delivery or they are argued about later without evidence.

SLC applied by reflex. See above: where the carrier loaded, the statute says it has no effect except for freight concealed by packages.

The BOL lives only on the driver’s phone. A photo in a text thread is not a record, and your invoice packet, your claim file and your part 379 obligation all want the same document.

FAQ

Who issues the bill of lading? The carrier. 49 CFR 373.101 puts the duty on the motor carrier — “Every motor carrier subject to § 373.100 shall issue a receipt or bill of lading” — and 49 U.S.C. 14706(a)(1) says the same of carriers subject to it. In day-to-day practice the shipper’s system prints the form and the driver signs for receipt, which is why people assume the shipper issues it. That is a workflow, not the legal duty, and the distinction matters when a bill is missing or wrong.

What is the difference between a straight bill of lading and an order bill of lading? Whether the goods are consigned to someone or to the order of someone. A bill is nonnegotiable — a straight bill — when it “states that the goods are to be delivered to a consignee,” and endorsing it neither makes it negotiable nor gives the transferee any additional right. It is negotiable — an order bill — when it states delivery “to the order of a consignee” and carries no agreement on its face that it is not negotiable (49 U.S.C. 80103). The practical difference: with an order bill, the paper controls release of the freight.

What does shipper load and count mean? That the shipper loaded and counted, and the carrier is not vouching for what is inside. The statutory phrase is “shipper’s weight, load, and count,” and 49 U.S.C. 80113(b) treats yard variants like SLC as “words of the same meaning.” What it does not mean is that the notation by itself settles a shortage: the statute lists three conditions and joins them with “and,” and 80113(d)(2) says the words have “no effect except for freight concealed by packages” when the carrier did the loading.

How long do I have to keep bills of lading? Appendix A to 49 CFR part 379 sets one year for copies of bills of lading and similar shipping documents, and one year for order-to-notify bills taken up and canceled. Treat that as a floor rather than a schedule. 49 CFR 379.3 says the part does not excuse longer retention required by anyone else, your own broker transaction record runs three years under 49 CFR 371.3(b), and a cargo claim can still be within its suit window after your BOLs would have aged out.

Related reading

• Bill of lading generator — fill and print one, every field cited
• What is a rate confirmation? Fields, template, and records
• Carmack Amendment: cargo claim deadlines and limits
• Detention fees: rates, rules, and how to bill them
• Lumper fees: what’s normal, who pays
• Co-brokering vs double brokering